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Notes on the Tax Treatment of Structures

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Author Info
Roger H. Gordon
James R. Hines Jr.
Lawrence H. Summers

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Abstract

More than three quarters of the United States tangible capital stock represents structures. Tax policies potentially have a major impact on both the level and composition of investment in structures and equipment. This point is explicitly recognized in most discussions of the effects of capital income taxation. Two aspects of the taxation of structures --the relative burden placed on structures as opposed to equipment investment and the non-taxation of owner occupied housing under the income tax -- have attracted substantial attention in recent years. This paper explores these two aspects of the taxation of structures investments. While the tax system may well have a potent impact on the level and composition of structures investment, this paper argues that conventional analyses of these effects are very misleading. We reach two main conclusions. First,under current tax law, certain types of structures investment are very highly tax favored. Structures can be transferred and therefore depreciated more than once, and structures may be readily financed with tax-favored debt. Overall, itis unlikely that a significant bias towards equipment and against structures exists under current law. Second, the conventional view that the tax system is biased in favor of homeownership is wrong. Because of the possibility of "tax arbitrage" between high bracket landlords and low bracket tenants, the tax system has long favored rental over ownership for most households. The 1981 reforms by reducing the top marginal tax rate reduced this bias somewhat.

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Paper provided by National Bureau of Economic Research, Inc in its series NBER Working Papers with number 1896.

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Date of creation: Dec 1987
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Handle: RePEc:nbr:nberwo:1896

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Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.:
  1. Alan J. Auerbach, 1985. "Real Determinants of Corporate Leverage," NBER Working Papers 1151, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
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  2. Constantinides, George M, 1983. "Capital Market Equilibrium with Personal Tax," Econometrica, Econometric Society, vol. 51(3), pages 611-36, May. [Downloadable!] (restricted)
  3. Patric H. Hendershott & David C. Ling, 1984. "Trading and the Tax Shelter Value of Depreciable Real Estate," NBER Working Papers 1267, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  4. James M. Poterba & Lawrence H. Summers, 1985. "The Economic Effects of Dividend Taxation," NBER Working Papers 1353, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
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  5. White, Michelle J, 1983. " Bankruptcy Costs and the New Bankruptcy Code," Journal of Finance, American Finance Association, vol. 38(2), pages 477-88, May. [Downloadable!] (restricted)
  6. Don Fullerton & Roger H. Gordon, 1983. "A Reexamination of Tax Distortions in General Equilibrium Models," NBER Chapters, in: Behavioral Simulation Methods in Tax Policy Analysis, pages 369-426 National Bureau of Economic Research, Inc. [Downloadable!]
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  7. Alan J. Auerbach & James M. Poterba, 1986. "Tax Loss Carryforwards and Corporate Tax Incentives," NBER Working Papers 1863, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
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  8. Jensen, Michael C. & Meckling, William H., 1976. "Theory of the firm: Managerial behavior, agency costs and ownership structure," Journal of Financial Economics, Elsevier, vol. 3(4), pages 305-360, October. [Downloadable!] (restricted)
  9. Harvey S. Rosen, 1985. "Housing Subsidies: Effects on Housing Decisions, Efficiency, and Equity," NBER Working Papers 1161, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  10. David F. Bradford & Don Fullerton, 1982. "Pitfalls in the Construction and Use of Effective Tax Rates," NBER Working Papers 0688, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  11. Stiglitz, Joseph E., 1983. "Some aspects of the taxation of capital gains," Journal of Public Economics, Elsevier, vol. 21(2), pages 257-294, July. [Downloadable!] (restricted)
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  12. Modigliani, Franco, 1982. " Debt, Dividend Policy, Taxes, Inflation and Market Valuation," Journal of Finance, American Finance Association, vol. 37(2), pages 255-73, May. [Downloadable!] (restricted)
  13. Titman, Sheridan D, 1982. " The Effects of Anticipated Inflation on Housing Market Equilibrium," Journal of Finance, American Finance Association, vol. 37(3), pages 827-42, June. [Downloadable!] (restricted)
  14. Rosen, Harvey S., 1985. "Housing subsidies: Effects on housing decisions, efficiency, and equity," Handbook of Public Economics, in: A. J. Auerbach & M. Feldstein (ed.), Handbook of Public Economics, edition 1, volume 1, chapter 7, pages 375-420 Elsevier. [Downloadable!] (restricted)
  15. Gailen L. Hite & Anthony B. Sanders, 1981. "Excess Depreciation and the Maximum Tax," Real Estate Economics, American Real Estate and Urban Economics Association, vol. 9(2), pages 134-147. [Downloadable!] (restricted)
  16. Jeremy I. Bulow & Lawrence H. Summers, 1984. "The Taxation of Risky Assets," NBER Working Papers 0897, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
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  17. Alan J. Auerbach & James R. Hines Jr., 1986. "Tax Reform, Investment, and the Value of the Firm," NBER Working Papers 1803, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  18. Myers, Stewart C., 1977. "Determinants of corporate borrowing," Journal of Financial Economics, Elsevier, vol. 5(2), pages 147-175, November. [Downloadable!] (restricted)
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Cited by:
(explanations, Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.)

  1. Andrew B. Lyon, 1989. "Did ACRS Really Cause Stock Prices to Fall?," NBER Working Papers 2990, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  2. Don Fullerton & Yolanda K. Henderson, 1990. "The Marginal Excess Burden of Different Capital Tax Instruments," NBER Working Papers 2353, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  3. Lawrence H. Summers, 1987. "Should Tax Reform Level the Playing Field?," NBER Working Papers 2132, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  4. Andrew Narwold, 2004. "Ownership of Residential Rental Property in Regional Housing Markets," ERSA conference papers ersa04p494, European Regional Science Association. [Downloadable!]
  5. Lawrence H. Summers, 1988. "Investment Incentives and the Discounting of Depreciation Allowances," NBER Working Papers 1941, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  6. Roger Gordon & Laura Kalambokidis & Joel Slemrod, 2003. "A New Summary Measure of the Effective Tax Rate on Investment," NBER Working Papers 9535, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  7. Andrew Coleman, 2008. "Tax, Credit Constraints, and the Big Costs of Small Inflation," Working Papers 08_14, Motu Economic and Public Policy Research. [Downloadable!]
  8. A. Lans Bovenberg & Lawrence H. Goulder, 1989. "Promoting Investment under International Capital Mobility: An Intertemporal General Equilibrium Analysis," NBER Working Papers 3139, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  9. Alan J. Auerbach & David Reishus, 1990. "The Effects of Taxation on the Merger Decision," NBER Working Papers 2192, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  10. James R. Hines Jr., 2002. "On the Timeliness of Tax Reform," NBER Working Papers 8909, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  11. Don Fullerton & Andrew B. Lyon, 1989. "Tax Neutrality and Intangible Capital," NBER Working Papers 2430, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  12. Mihir A. Desai & William M. Gentry, 2003. "The Character and Determinants of Corporate Capital Gains," Department of Economics Working Papers 195, Department of Economics, Williams College. [Downloadable!]
    Other versions:
  13. Alan J. Auerbach & James M. Poterba, 1986. "Tax Loss Carryforwards and Corporate Tax Incentives," NBER Working Papers 1863, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  14. Don Fullerton & James B. Mackie, 1989. "Economic Efficiency in Recent Tax Reform History: Policy Reversals or Consistent Improvements?," NBER Working Papers 2593, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  15. Jonathan Skinner, 1989. "Housing Wealth and Aggregate Saving," NBER Working Papers 2842, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  16. Judith Yates, 2003. "'The more things change?' An overview of Australia's recent home ownership policies," European Journal of Housing Policy, Taylor and Francis Journals, vol. 3(1), pages 1-33, January. [Downloadable!] (restricted)
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